‘VIRGINIA: IN THE CIRCUIT COURT FOR THE CITY OF LYNCHBURG ) ==B ) ) Plaintiff, 0 % ) ) AMENDED COMPLAINT ) OFFICER, ) 905 Court Street ) Lynchburg, VA 24504 ) d Defendant. ) fee eee eee Ee COMES NOW, Pleintifi QE and moves for Judgment against the Defendant, Officer QED on the grounds and in the amount as hereinafter set forth: 1 On the 21% day of July, 2020, Plaintiff was operating his vehicle around the 1500 Block of 6* Street, Lynchburg, Virginia. 2. On the dete and at the place aforesaid, QUEM wes operating his vehicle within Lynchburg City Limits when Officer QED initiated a traffic stop for allegedly “squealing” his tires and for the belief that QIN ’2s operating the vehicle without a license. 3. Aftcr initiating the traffic stop, Officer QE ordered! fo exit the vehicle. Officer QIN hen proceeded to forcefully perform an anal cavity search on (GERBER in clear view of the public, without prior notice or a medical professional to assist. Officer QIMMMMMNMIED continued this search despite QUMEMPequests to stop, in clear violation of the Plaintiff's liberties, the United States Constitution, Virginia Code Section 19.2- 59.1 and Lynchburg City Police Department's policies. ae COUNT ONE: SEXUAL ASSAULT AND BATTERY 4, The Defendant, Officer QIN committed assault and battery againstPlein IM in that he: ‘A. Performed an anal cavity searchin broad daylight inthe pubic view without reasonable cause; B> Started a search of the Plaintiff's anal cavity without giving the Plaintiff prior notice; c. Searched the Plaintiff's anal cavity forcefully; D. Continued to search the Plaintiff's anal cavity despite the Plaintiff repeatedly objecting, requesting the Defendant to stop; E, Violated the Plaintif?s liberties under the United States Consti F. Violated Virginia Code Section 19.2-59.1; and G, Violated the Lynchburg Police Department's written policy on anal cavity searches. 5. Asadireet and proximate result of the sexual essault and battery at the hands of the Defendant, Plaintif? QMRMIBMD 2s caused to sustain serious embarrassment, harm to reputation, and physical injuries, has suffered, and will continue to suffer great pain of body, has incurred and will incur in the future medical bills in an effort to be cured of his physical injuries. WHEREFORE, Plaintiff demands judgment against the Defendant in the form of compensatory damages for sexual assault and battery in the sum of TWO HUNDRED AND FIFTY THOUSAND DOLLARS ($250,000.00) with interest from July 21, 2020, at the statutory rate until paid and his costs in this behalf expended, and demands judgment against the Defendant in the form of punitive damages for sexual assault and battery in the sum of TWO HUNDRED AND FIFTY THOUSAND DOLLARS ($250,000.00) with interest from July 21, 2020, at the statutory rate until paid and his costs in this behalf expended.‘TRIAL BY JURY IS DEMANDED. W. Cameron Warren, Esq. Virginia State Bar Number 83436 Pack Law Group 423 Bast Main Street Bedford, VA 24523 540-586-7225 (Telephone) 540-586-1227 (Facsimile)